Ghost(1990) [Emergency Room Ghost]: Dies (off-screen) of unspecified causes, some time before the story begins; he appears as a ghost to Patrick Swayze in the hospital.

Ally McBeal: Happy Trails(1998) [Judge Dennis 'Happy' Boyle]: Dies of a heart attack in his courtroom. (This episode was produced after Phil's real-life death; most of his screen time consisted of unused footage filmed for a previous episode, and his death scene was edited from a blooper outtake of Phil falling asleep on the set.)